THE GO-AHEAD GROUP PLC
SLAVERY AND HUMAN TRAFFICKING STATEMENT AS REQUIRED UNDER S54 OF THE
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MODERN SLAVERY ACT FOR THE 2015/2016 FINANCIAL YEAR
INTRODUCTION FROM DAVID BROWN, GROUP CHIEF EXECUTIVE
The Go-Ahead Group PLC and its subsidiaries (“Go-Ahead”/ “us”/ “we”/ “our”/the “Group”)
is committed to ensuring that all of its business dealings are carried out in full compliance
with relevant laws and, in doing so, we endorse the implementation and promotion of ethical
business practices to protect workers from being abused and exploited both within Go-Ahead
and its supply chains. Go-Ahead are committed to improving our practices to combat slavery
and human trafficking and we have taken significant steps in the Financial Year to promote
and improve our ongoing commitment to eliminating abuse and exploitation in the workplace
as detailed in this Statement.
A) ORGANISATION'S STRUCTURE
The subsidiaries of The Go-Ahead Group PLC are, predominantly, providers of public
transport services in the UK Bus and Rail sectors. The Go-Ahead Group PLC has its
registered office in Newcastle, England and the Group has over 26,000 employees in the UK.
Many of our subsidiaries in the UK have a turnover in excess of £36 million in this Financial
Year and this Statement applies to all of our UK operating subsidiaries regardless of their
turnover, compliance with it having been endorsed by the Board of Directors of each
operating subsidiary. In the 2016/17 Financial Year we will commence operation of Bus
Services in Singapore and, in 2020, Rail Services in Germany each via locally based
subsidiaries, these overseas subsidiaries will, when fully operational, be reported on in
subsequent statements. All the steps taken in this statement are taken by the Go-Ahead Group
for itself and each of its operational subsidiaries referred to in B) below.
B) OUR BUSINESS
The Group’s business is organised into 12 operating subsidiaries. The Group operates a
devolved management structure, however procurement is one of the support functions which
is, primarily, provided centrally, affording the Group’s centre significant control over the
supply chains of the subsidiary operations.
C) OUR SUPPLY CHAINS
Our supply chains include manufacturing, primarily of bus and rail vehicles, parts and
uniforms, services (such as cleaning of stations, vehicles and depots) and outsourced IT
hardware and software services. As procurement is a centralised function the Group is able to
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References in this Statement to the “Act” are references to the “Modern Slavery Act 2015”.
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implement the due diligence and contractual processes referred to below to give effect to GoAhead’s anti slavery and trafficking policy.
D) OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our
supply chains or in any part of our business. Our anti-slavery policy reflects our commitment
to acting ethically and with integrity in all our business relationships and to implementing and
enforcing effective due diligence and contractual compliance to ensure slavery and human
trafficking is not taking place anywhere in our supply chain.
E) DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
1) Go-Ahead has identified the following areas of the business and or supply chain as being
areas which carry the highest susceptibility to the risk of employing slave or trafficked labour:
all manufacturing processes or other processes where low skilled labour is required or
managed e.g. cleaning / security / gateline colleagues (“At Risk Functions” / “ARFs”).
2) Suppliers of ARFs were asked to complete Go-Ahead’s “Modern Slavery Due Diligence
Questionnaire” and where deemed necessary following an analysis of those results, we may
choose to exercise contractual rights of audit or require those Suppliers to provide statements
attesting to their compliance with the Act. We will also monitor our Supplier’s statements
made under s54 of the Act to assess their compliance with the requirements of the Act.
3) In order to mitigate the risk of slavery and human trafficking occurring in our supply
chains Go-Ahead’s Procurement Strategy, Policy and Procedures Manual was updated for
year 2015-2016, and the Supplier Code of Conduct and Standard Terms of Purchase for
Goods and Services have been updated to include specific obligations under the Act on our
Suppliers.
4) At Group level we have researched available training courses for our colleagues and we
will commence the delivery of this training, which will alert colleagues to ARFs, the risks of
slavery and human trafficking occurring and how to be alert to its existence, in the 2016/17
Financial Year.
F) SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply
chain and contractors support our values on this subject we require our Suppliers to abide by
Go-Ahead’s anti-slavery and trafficking policy (or their own equivalent) via our contract
terms.
In 2016-2017 KPIs will be created to quantify and capture a range of Group “Sustainability
Objectives”, including requirements of the Act.
G) TRAINING
1) Outsourced ARFs. Where an ARF is outsourced we have identified training resources to
suit our business and in the 2016/17 Financial Year will commence the process of training
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those who procure the ARF and those employees who manage the delivery of the ARF at Op
Co Level (contract managers / HR / Depot managers/ Depot Supervisors /Station Managers /
Station Supervisors /Relevant Directors). We have also updated our standard contract terms
in order that, when signed, suppliers will be contractually obliged to provide analogous
training to those who are engaged in the supply of services to Go Ahead.
2) Self Provided ARFs. Where the ARF is provided “in house” we have identified training
resources to suit our business and in the 2016/17 Financial Year we shall commence the
process of training all those involved in the establishment and delivery of that ARF
(HR/Relevant Directors/Managers, supervisors and those persons who perform the ARF).
All Go-Ahead colleagues have access to a whistleblowing process which will allow them to
report any concerns that they may have in a confidential and secure manner.
Given the scope of possible participants we will adopt many different modes of delivery for
training such as computer based training, leaflets and classroom training. Training provided
will, as a minimum, deal with the following areas: how to spot a slavery or trafficking issue /
why slavery and trafficking is wrong / types of slavery and trafficking / how to report a
concern.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and
constitutes our Group's slavery and human trafficking statement for the financial year
ending 2nd July 2016.
Group Chief Executive
The Go-Ahead Group PLC.
Date: 14th July 2016
The Board of Go North East Limited, a subsidiary of the Go-Ahead Group PLC, have
endorsed, approved and adopted this Modern Slavery Act statement for and on behalf
Go North East Limited.
Managing Director
Go North East Limited
28th July 2016
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